Managing mould
Queensland Teachers' Journal, Vol 129 No 7, 27 September 2024, page 22.
Mould generally grows in warm or moist conditions, including where there is water leakage, and so is a specific and potential work health and safety (WHS) hazard. Queensland’s tropical climate makes exposure to the hazard of mould a foreseeable risk. Poor building maintenance and hygiene also create mould infestation risks.
Mould may cause or exacerbate health issues. Depending on the level of exposure, some people may experience impacts, such as allergies, headaches, itching, skin rashes, sore throat and a runny nose. Further, mould exposure can also trigger significant reactions in people with asthma, mould allergies or weakened immune systems.
WHS Primary Duty of Care
The WHS Act 2011 states that the person conducting the business or undertaking (PCBU) must ensure, as far as reasonably practicable, the health and safety of workers and others (students, parents). That duty (section 19) also expects safe systems of work to be in place. Therefore, the department must ensure:
the provision and maintenance of a work environment without risk to health and safety
that the health of workers and the conditions at the workplace are monitored for the purpose of preventing illness or injury of workers arising from the conduct of the business or undertaking.
It is more than reasonably practicable (as defined under (section 18) of the WHS Act) for the Department of Education to resource regions to ensure the environmental safety of workplaces. Cost is the last consideration under the definition of reasonably practicable. Not testing because it costs too much is not okay.
Managing mould
The department’s mould fact sheet provides direction on proactively managing and then responding to mould: “Reduce the risk of mould related problems by ensuring that mould is removed safely and ensure that action is taken to stop or minimise future mould growth. Sometimes you can see mould when it discolours walls, ceilings and other surfaces. If not visible, you might detect a musty, unpleasant odour instead. Check for moisture or condensation in corners of rooms, carpeted areas and near air-conditioner units. Plants growing on, or close to, external walls can hold in moisture and promote mould growth. Make sure your walls and weep holes are clear of plants and soil.”
Consultation
As workers in schools, teachers have the right to be consulted in relation to any WHS matter and are entitled to be informed about the results of testing and related mould management strategies. To be explicit, the WHS Act legislated a duty to consult workers (s47-49) and give them a reasonable opportunity:
- to express their views and to raise work health or safety issues
- to contribute to the decision-making process relating to the matter
- to have their views taken into account
- to hear the outcome of the consultation in a timely way.
Code of practice
Work Health and Safety Queensland has a code of practice on WHS consultation, cooperation and coordination (which has the standing of the legislation).
In terms of the primary duty of care to the health and safety of workers, the department is charged with leading, with regions and workplaces, an active culture of real monitoring of mould in schools, tracking weather, and having a strategy for managing school facilities during vacation periods. Classrooms/rooms that have an established susceptibility should have their own management plan in place. Basically, shutting up schools for weeks with no management of airflow and humidity is not a safe system of work and foreseeably exposes workers to a physically and psychosocially unsafe workplace.
Central Office, in partnership with regions, should have clear, safe systems of work in place in relation to managing mould in state schools and for monitoring the health and safety of workers in all its workplace. It doesn’t. The Department of Education needs to lead a response to mould management, not with a task focussed lens, but with a WHS lens that has safe systems of work and consultation with workers at the heart of the response.